NY 857963
DEC 12 1990
CLA-2-72:S:N:N1:117 857963
Mr. Matthew Chang
C. Itoh & Co. (America) Inc.
335 Madison Avenue
New York, N.Y. 10017
RE: The applicability of subheading 9802.00.60 to certain basic
steel mill products.
Dear Mr. Chang:
In your letter dated November 9, 1990 you requested a tariff
classification ruling.
Hot-rolled nonalloy steel coils of U.S. origin will be
exported to Greece for processing and subsequently returned to
the U.S. for further processing.
Subheading 9802.00.60, HTS, provides that any article of
metal (as defined in U.S. note 3(d) of this subchapter)
manufactured in the United States or subjected to a process of
manufacture in the United States, if exported for further
processing, and if the exported article as processed outside the
United States, or the article which results from the processing
outside the United States, is returned to the United States for
further processing may be entered with duty upon the value of
such processing outside the United States upon compliance with
Customs Regulations.
To meet the requirements of "further processing" some
operation must be applied to the metal that will change its shape
or form or impart new and different characteristics, which become
an integral part of the metal itself.
Upon their arrival in Greece, the American-made coils will
be subjected to the following operations: uncoiling, pickling,
side-trimming, oiling, descaling, coil end-cutting, cold-
reducing, electro-cleaning, tempering, annealing, tin plating,
oiling ( a second time), shearing (in some cases), recoiling (in
other cases) and packing. This tin plated steel, with
thicknesses varying from .007 inches to .0142 inches and widths
ranging from 20 inches to 50 inches, will be reimported into the
U.S. to undergo further processing such as unpacking, uncoiling,
slitting, shearing, and forming.
In this respect, the operations performed in Greece and in
the U.S. appear to satisfy both the foreign and domestic segments
under subheading 9802.00.60. Accordingly, the merchandise may be
entered under subheading 9802.00.60 with duty on the cost or
value of the processing abroad upon compliance with the
applicable regulations.
The applicable subheading for the tin plated steel with a
width of 24 inches or more will be 7210.12.00, Harmonized Tariff
Schedule of the United States (HTS), which provides for flat
rolled products of iron or nonalloy steel, of a width of 600 mm
or more, clad, plated, or coated, plated or coated with tin, of a
thickness of less than 0.5 mm. The rate of duty will be 3.5
percent ad valorem.
The applicable subheading for tin plated steel with a width
of less than 24 inches will be 7212.10.00, Harmonized Tariff
Schedule of the United States (HTS), which provides for flat
rolled products of iron or nonalloy steel, of a width of less
than 600 mm, clad, plated, or coated, plated or coated with tin.
The rate of duty will be 3.5 percent ad valorem.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport